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Nigeria Action Plan Review 2023-2025

Nigeria’s third action plan continues open government reforms that aim to tackle corruption. Dedicated funding and a strong coalition of reformers set commitments to open the budget process and increase beneficial ownership transparency apart. Successful implementation will likely depend on whether open government momentum is sustained under the new administration.

Nigeria’s third action plan has 13 commitments covering the policy areas of fiscal openness, anti-corruption and integrity, right to information, natural resource governance, inclusion, public service delivery, and civic space.[1] Promising commitments continued from prior action plans include beneficial ownership transparency and strengthening transparency and participation in budget and audit processes. Building on the passage of the Climate Change Act 2021, the action plan introduces a new policy aimed at increasing transparency of government actions around climate change.

The IRM assessed commitments to strengthen open budgeting and beneficial ownership transparency as having the greatest promise for open government results. Commitments 1 and 2 aim to further strengthen transparency of key budget and audit documents and opportunities for public input. Commitment 9 seeks proactive disclosure of beneficial owners (BOs) of all corporate entities in Nigeria. Both commitments build on the momentum gained under previous action plans and benefit from a coalition of government and civil society advocates.

Civil society and government participants agree that the co-creation process was more collaborative than for previous action plans.[2] According to the Nigeria OGP Secretariat, fiscal transparency, beneficial ownership, and access to information reforms continued as the public and civil society organisations (CSOs) prioritised openness and accountability in the management of public resources. According to OGP Point of Contact for Nigeria Gloria Ahmed, the inclusion of climate change was also a response to the citizens of Nigeria’s increasing demand for action from the government.[3]

A drafting committee collected government and nongovernment input and shared a draft for comments. The third action plan was ultimately assented to by former President Muhammadu Buhari. National Steering Committee meetings show that some input on the action plan emerged from government-civil society discussions during the implementation of the previous action plan.[4] Nigeria’s OGP website and Google Drive have improved public information on Nigeria’s OGP processes and progress.[5] However, there remains an opportunity to publish more detailed documentation of co-creation and implementation activities and outcomes.

Revisiting the aim and activities for several commitments could help to clarify the path to impactful implementation. Many commitments are carried verbatim over from previous action plans despite having faced significant obstacles to implementation (Commitments 10 and 13). For some commitments, a review of the action plan to ensure alignment between the commitment’s objective and planned activities could help to achieve desired results. For instance, Commitment 7 does not include activities that would directly address the aim to improve access to information for disadvantaged groups. The ambition for Commitment 10 could be strengthened by identifying specific policy decisions that the public forums planned will influence.

The IRM recommends taking a strategic approach to implementation to maximise results. The OGP Secretariat and National Steering Committee can sensitise and closely coordinate with responsible implementers. Sensitisation can aim to update and galvanise support from key government officials and National Assembly members under the new government. Coordination can focus on prioritising implementation of activities that go beyond existing practice. Sufficient funding presented a challenge to implementation under the previous action plan.[6] The National Steering Committee is recommended to evaluate where there is a gap in allocated government, partner, or civil society budget for planned milestones and opportunities to address these gaps.

Promising Commitments in Nigeria’s 2023–2025 Action Plan

The following review looks at the three commitments that the IRM identified as having the potential to realise the most promising results. Promising commitments address a policy area that is important to stakeholders or the national context. They must be verifiable, have a relevant open government lens, and have modest or substantial potential for results. This review also provides an analysis of challenges, opportunities, and recommendations to contribute to the learning and implementation process of this action plan.

Table 1. Promising commitments

Promising Commitments
Commitment Cluster 1 Open Budgets: Promises to strengthen transparency and public participation practices across the budget and audit cycles.
Commitment 9: Aims to establish a public register of Beneficial Owners of Corporate Entities in line with the Beneficial Ownership Data Standards.

[1] Open Government Partnership (OGP), Nigeria Action Plan 2023–2025, March 2023, https://www.opengovpartnership.org/wp-content/uploads/2023/03/Nigeria_Action-Plan_2023-2025.pdf

[2] Odeh Friday, Accountability Lab, interview by IRM researcher, 21 June 2023; Gabriel Okeowo, BudgiT, interview by IRM researcher, 28 June 2023; Alfred Okoh, Technical Assistant to the Director General, Budget Office of the Federation, interview by IRM researcher, 12 July 2023; Joachim Ojomuyide, National Orientation Agency, interview by IRM researcher, 11 July 2023.

[3] Dr. Gloria Ahmed, Director, Special Duties in the Federal Ministry of Finance, Budget and National Planning and also National Coordinator and Point of Contact-Open Government Partnership Nigeria.

[4] OGP Nigeria Repository, https://drive.google.com/drive/folders/1Wt_JCCqJgMlotNHmubU2ViCZBjwlA19x?usp=share_link.

[5] OGP Nigeria, https://www.ogpnigeria.gov.ng/; OGP Nigeria Repository, 2023–2025, https://drive.google.com/drive/folders/1o2Vk1wjjYs56FE7UUDgb7MH7f7vDPQrn.

[6] OGP, Nigeria Results Report 2019–2022, 22 June 2023, https://www.opengovpartnership.org/documents/nigeria-results-report-2019-2022/.

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